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Case 18-2868, Document 276, 08/09/2019, 2628224, Page61 of 77 mission of which is purportedly to “spread the word for victims of human trafficking”. EXHIBIT MM at 17; see also EXHIBIT LL. According to Brittany Henderson, the Rule 30(b)(6) designee of VRS, plaintiff has “continued to try to promote Victims Refuse Silence at every possible chance she gets ...” EXHIBIT MM at 17-18. Plaintiff participated in an interview in New York with ABC in “the beginning of 2015,” id. at 27, so that she could “promote the charity, so that she could start getting her mission out to the public.” /d. at 28. Having affirmatively injected herself into the public spotlight in connection with these issues, plaintiff cannot now be heard to argue that this Lerman factor has not been satisfied. Cf Contemporary Mission, 842 F.2d at 618-19 (finding the plaintiffs' assertion that they have assumed a private life was “belied by the fact that they continued to thrust themselves into the public eye” through their conduct on behalf of a non-for- profit organization). 4. Plaintiff has maintained regular and continuing access to the media. Plaintiff has had substantial access to the media. Ms. Churcher has answered every call or email sent by plaintiff. Plaintiff's lawyers have regularly communicated with the media. Plaintiff and her lawyers have been interviewed by numerous major media organizations. Accordingly, the First Amendment requires that public figures like plaintiff claiming defamation must establish actual malice—actual and material falsity or a high degree of awareness of probable falsity—by clear and convincing evidence. E.g., Masson v. New Yorker Magazine, Inc., 501 U.S. 496, 510 (1991). D. Plaintiff must also prove actual malice to overcome the defenses of reply and pre-litigation privilege. The qualified privilege of reply to a defamatory attack is a complete defense to a claim of defamation. Shenkman v. O'Malley, 157 N.Y.S.2d 290, 294, 297 (App. Div. 1956). The defense 54